Transfer Pricing Considerations for Procurement and Sourcing Entities

Abstract

This article deals with the arm’s length determination of transfer prices for intercompany sourcing activities. In particular, it challenges the view that intercompany sourcing activities represent merely routine services that should be entitled to a low cost-based remuneration without considering any markup on the procurement cost. On the contrary, sourcing activities are usually part of the key value chain of MNE groups meaning that the inclusion of the purchasing cost for raw materials or goods in the cost base is appropriate in the context of the application of the cost-plus method in accordance with the OECD Transfer Pricing Guidelines.